Dragon, Karen E. (CDC/NIOSH/EID) 

From: NIOSH OCAS (CDC) 


Sent: Thursday, November 19, 2015 9:12 AM 


To: Dragon, Karen E. (CDC/NIOSH/EID) 


Cc: Diana, Sherri A. (CDC/NIOSH/EID) (CTR) 


Subject: FW: Advisory Board on Radiation and Worker Health 


Attachments: 20151118 ADRWH Public Comment - Jon Lipsky.pdf 


Another public comment for Rocky Flats. 

From: Jon Lipsky 

Sent: Wednesday, 1\iovember 18, 2015 8:26 PM 

To: NIOSH OCAS (CDC) <ocas@cdc.gov> 

Cc: Rutherford, LaVon B. (CDC/NIOSH/DCAS) <lrrS@cdc.gov>; ' 

Subject: Advisory Board on Radiation and Worker Health 

Please include my attached public comment for the 11 /18/2015 Advisory Board on 

Radiation and Worker Health. 

Best regards, 

Jon Lipsky 

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Comments regarding the NIOSH White Paper, Rev. 4, dated August 12, 2015 


. Entitled "Evaluation of Petitioner Concerns About Data Falsification and Data 


Invalidation in RFP Building 123 Based on Worker Allegations and Issues 


Relating to the FBI Raid" by Mutty Sharfi and Dan Stempfley, Oak Ridge Associated 


Universities Team, Reviewed by LaVon Rutherford, DCAS 


November 18, 2015 Comments to the Advisory Board on Radiation and Worker Health 


By: Jon Lipsky, M.A.S. 


Reference my July 11, 2015 public comments that were not addressed in the August 

12, 2015 NIOSH White Paper, Revision 4, regarding Data Falsification. 

From May 1987 to March 1992 I was the principal-lead FBI agent regarding the criminal 

investigation at the Rocky Flats Nuclear Weapons plant, Golden, Colorado .. 

In March 1988 the U.S. Department of Energy, Environment, Safety, and Health, Office 

of Nuclear Safety, Washington, D.C. 20545 published "Technical Safety Appraisal of Building 

776/777 Rocky Flats Plant." In the interest of time please consider the following summary:" 

l. 	"Of the 85 concerns in this report, 39 address problems that were found by one or both 

of the earlier Technical Safety Appraisals of Rocky Flats Plant facilities." (DOE: 1988: 

Appendix A, p. 11-1 ). Nine (9) of the concerns were judged to be Category II 

seriousness, five (5) of which were addressed while the appraisal team was presentto develop realistic radiological operating rules, the effective enforcement of the rules 

and calibration of radiological instrumentation used for contamination control. (DOE: 

1988: Appendix A, p. 11-2). The appraisal painted a serious personal radiological 

problem at Rocky Flats. 

2. 	 "The pervasiveness of the deficiencies in the radiological program are (sic) 

symptomatic of a program that has not had adequate management attention." For 

example, radiation monitoring is adversely affected by poor quality instrumentation, 

inadequate calibration techniques, and improper use of equipment. (DOE: 1988: p. 4). 

3. 	 "The radiological health quality assurance program is ineffective as evidenced by 

some of the preceding concerns, failure to comply with DOE-prescribed standards, 

and deficiencies in maintaining exposure records and tracking bioassay samples." The 

appraisal team observed numerous violations of radiological procedures during the 

appraisal. (DOE: 1988: pp. 4-5}. 

The referenced 280-page March 1988 Technical Safety Appraisal of Building 776/777 

Rocky Flats Plant report refers to previous Technical Safety Appraisals of Rocky Flats. The 

reported "problems" amounted to 463 of the 1988 findings appears to have been systemic, 

multi-temporal and additional reasons to expand the Rocky Flats, Special Exposure Cohort 

petition 0192. 

Res.oet.ttullv swbmitted, 

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